Abstract: Cosmetics & Toiletries bids a fond farewell to David C. Steinberg in this, his final “Regulatory Review” column. Here, he describes how he would regulate cosmetics, after having followed and reported on them for more than 18 years.

After 18 years of writing for Cosmetics & Toiletries on cosmetic regulations, I decided to write this final column on how I think cosmetics should be regulated—referred to here as the Steinberg Administration. No one will agree with these propositions 100%, and many ideas will be controversial to regulators, industry and non-governmental organizations (NGOs), but this last column will hopefully stimulate some thought, intelligent discussion and possibly, change.

At a harmonization conference many years ago, a delegate from another country’s government asked me to write cosmetic regulations for her country. When I asked her why she wanted to regulate cosmetics, she replied because everyone else does. My advice for her was to copy someone else’s rules, and to think about why she wanted to regulate cosmetics. The next morning we met again, and her new reason for regulating cosmetics was to assure that those manufactured or imported into her country were safe. We agreed to work together, and 3-4 pages and a bill later, regulations were drafted.

The answer to why cosmetics must be regulated is the same today as it was back then—they must be safe. Cosmetic manufacturers also should only be allowed to make true and substantiated claims. While I fully believe in self-regulation with as few rules as possible and minimal government involvement and cost, the cosmetic industry needs good police to protect honest companies from companies who disregard the rules. To quote Edward Squibb, who proposed the formation of the U.S. Food and Drug Administration (FDA) in 1876, “This can only be accomplished by having penalties for violations, to be so severe that no one would ever think of not complying.”

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Biography: David C. Steinberg, Steinberg & Associates

David C. Steinberg founded Steinberg & Associates, a consulting firm based in Plainsboro, NJ, USA, in 1995. Co-founder of the graduate program in cosmetic sciences at Fairleigh Dickinson University, where he lectured for 18 years on cosmetic chemistry, Steinberg has more than 35 years of experience in marketing, technical service and regulatory affairs in the personal care industry. In addition, he was president of the Society of Cosmetic Chemists in 1991. Steinberg is a frequent speaker worldwide on cosmetic regulations and preservation as well as sunscreen and cosmetic ingredient chemistry. In 2009, he was honored as the first regulatory expert in personal care to be granted fellow status by the Regulatory Affairs Professional Society. He wrote the Alluredbook, Preservatives for Cosmetics, Third Edition.